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 To be entitled to the procedural protections of the Fourteenth Amendment, a party must demonstrate that her dismissal from the school deprived her of either a 'liberty' or a 'property' interest. Because property interests are creatures of state law, Perry v. Sindermann, 408 U. S. 593, 408 U. S. 599-603 (1972), a party must show at trial that a position as a student at a school is a 'property' interest recognized by state law. 

In Bishop v. Wood, 426 U. S. 341 (1976), the court upheld the dismissal of a policeman without a hearing; rejecting the theory that the mere fact of dismissal, absent some publicizing of the reasons for the action, could amount to a stigma infringing one's liberty: 'In Board of Regents v. Roth, 408 U. S. 564, we recognized that the nonretention of an untenured college teacher might make him somewhat less attractive to other employers, but nevertheless concluded that it would stretch the concept too far 'to suggest that a person is deprived of liberty' when he simply is not rehired in one job, but remains as free as before to seek another.' Id. at 408 U. S. ...

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